ICAEW's CPD Requirement Has Six Different Hour Figures

ICAEW does not have a CPD hours figure. It has six, and which one applies to you depends on two things at once: your category, and whether you are in practice. A comparison table that gives ICAEW a single number is wrong for at least five of the six populations it covers.

The instrument

The requirement is in the ICAEW CPD Regulations, which state that "They are effective from 1 November 2023", applying to CPD Years starting after that date. This was a substantial redesign rather than an adjustment, which is part of why so much published material still describes the previous regime.

The six figures

For Practice Members, the regulations require a Category 1 member to "undertake 40 CPD hours of which 30 hours must be relevant and verifiable"; a Category 2 member to "undertake 30 CPD hours of which 20 hours must be relevant and verifiable"; and a Category 3 member to "undertake 20 CPD hours of which 10 hours must be verifiable".

For Members Not in Practice, Category 1 requires a member to "undertake 40 CPD hours of which 15 hours must be verifiable"; Category 2 to "undertake 30 CPD hours of which 10 hours must be verifiable"; and Category 3 "at least 20 hours of CPD, of which 5 hours must be verifiable".

Read those two paragraphs against each other, because the structure is the interesting part. The totals are identical across the two groups — 40, 30 and 20 — and the verifiable sub-quotas are completely different. A Category 1 practice member owes 30 verifiable hours of their 40. A Category 1 member not in practice owes 15 of the same 40. The practice member's verifiable burden is double.

So ICAEW does not vary the quantity of learning by practice status. It varies how much of it has to be evidenced. That is a design choice worth noticing, because it says the Institute's concern with practitioners is provability rather than volume.

Regulation 9 defines relevant and verifiable CPD as activity meeting a specific learning outcome that can be evidenced — so the test has two limbs, an outcome and the proof of it, rather than proof alone.

One mandated subject, and it is not what the market is selling

Regulation 8(c) requires members to "Undertake a minimum of one hour's ethics training". It can be satisfied by ICAEW's own ethics module or by alternative ethics training achieving specified learning outcomes linked to the ICAEW Code of Ethics.

That is the only subject ICAEW mandates. There is no requirement in the regulations for technology, for artificial intelligence, for audit, for tax, or for anything else. Members choose CPD relevant to their role and development needs, and the single compulsory topic is ethics.

ICAEW states the consequence plainly in its own commentary: every member must address ethics as part of their professional development each year, and failing to do so would put a member in breach of their CPD obligations.

It is worth saying what follows from that, because a good deal of marketing currently implies otherwise. ICAEW does not require AI-related CPD. Neither does ACCA, which mandates no subject at all within its 40 units, nor IFAC, nor IESBA, nor AICPA and CIMA. ICAEW offers a GenAI Accelerator Programme, but that appears in its catalogue as a product rather than as a requirement. The obligation that AI use actually engages is the professional ethics one — and in ICAEW's case there is a mandated hour of ethics training sitting right there to discharge it against, which is a considerably more honest proposition than a compliance threat. We set the position out in full in our piece on why the EU AI Act does not require AI training.

Where ICAEW sits against the other UK and Irish bodies

Three contrasts are worth drawing, because they are the ones comparison tables flatten.

ICAEW tiers; ACCA does not. ACCA's Membership Regulation 4(4)(a) applies one figure to all members regardless of class — 40 units with at least 21 verifiable — and expressly catches suspended members. ICAEW runs six combinations. Our analysis of how ACCA's 40-unit rule applies to only one of three routes covers the ACCA side, where the variation sits in the routes rather than in the membership classes.

ICAEW mandates ethics; ACCA mandates no subject. ACCA's regulation does require every member to maintain competence in professional ethics, but it attaches no number of hours to it. ICAEW attaches one hour. CIMA, by contrast, prescribes no hours or units at all, as our comparison of ACCA and CIMA sets out.

And ICAEW's verifiable concept is stricter than ACCA's. ACCA's rulebook test for verifiability is provability alone: a unit is verifiable if the member can prove they were involved in an acceptable learning activity. ICAEW's Regulation 9 requires the activity to meet a specific learning outcome as well as being evidenced. The three-question test that includes relevance and application, which everyone quotes as ACCA's standard, is ACCA guidance rather than its rule — whereas ICAEW has put the outcome requirement in the regulation itself.

What we could not establish

One significant gap, and it matters for anyone trying to work out which figure applies to them.

We have the six requirements but not the criteria that put a member into Category 1, 2 or 3. The regulations set the hours by category; what determines the category — role, employer size, the nature of the work, self-assessment — is not something we have verified, and we are not going to guess at it. Any member working out their own obligation needs that answer, and the place to get it is the regulations themselves rather than any summary, including this one.

A second caution on sourcing. ICAEW's article pages are client-side rendered and returned only navigation markup to us, including its flagship page on the rules and guidance accountants need to follow on AI. Everything above comes from ICAEW's own PDFs, which served normally, and from its published commentary. If you are relying on this professionally, read the regulations directly.

And one observation about ICAEW's position on AI ethics that is easy to misrepresent. ICAEW's Ethics and Artificial Intelligence guide of October 2024 is a roundtable report, recording participants' views, not an ICAEW position statement. It is candid that opinions were divided on whether the Fundamental Principles in ICAEW's Code of Ethics adequately cover AI use, with some participants considering them sufficient and others wanting AI-specific guidelines. That is a useful thing to know and a bad thing to cite as settled ICAEW policy.

The practical upshot

Establish your category and your practice status before you count anything, because those two together pick one of six requirements. Count your verifiable hours separately from your total, since for a Category 1 practice member the verifiable figure is 30 of 40 and that is the binding constraint. Make sure one of those hours is ethics, because it is the only subject ICAEW compels and the easiest to overlook precisely because it is small.

And treat the 2023 redesign as the dividing line in any source you read. Material describing ICAEW CPD without reference to categories and the practice split predates November 2023.

For the structural question of why ICAEW is free to design its scheme this way while other bodies choose completely differently, see our explainer on where accountants' CPD requirements come from. The regulations themselves are published by ICAEW.